The Industrial Relations Advisers,

Management & Labour Laws Consultants


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Ref. No. C-95                                               Date:  19-04-2003



The Chairman,

Employees Old-Age Benefits Institution,

EOBI House, 190/1/B,

Block–2, P.E.C.H.S,



Sub: Undue & illegal harassment by some officials of EOBI


Dear Sir,


We would like to address you as under: –


1- By the amendments in the Employee Old-Age Benefits Act, 1976 and the Provincial Employees Social Security Ordinance, 1965 the long standing demand of employers to save them from undue harassment by of the officials of these Institutions was accepted by introducing the self-assessment scheme under both the laws to the dislike of the officials of these Institutions.


2- By further amendments in both these laws inspection/checking of records by the officials of both the Institutions have been restricted once in a year and not more than of two years. These restrictions imposed by both laws have further taken away the opportunities of harassing of employers by the officials of these Institutions under the pretext of checking of records and they are not happy with both the new amendments.


3- Some officials of the EOBI have invented another method of harassment, they are sending letters to the employers, photocopy attached, to provide records of 6 months under Section 12(1)(a) of the Act to them in their office as under: –


1.)       Pay Roll/ Wages Register

2.)      Wages Payment Vouchers

3.)      Attendance Register

4.)      General Ledger

4- Section 10 provides for the employers to maintain records and submit such returns as may be provided in the Regulations. The Regulation 5 of the EOB (General) Regulations, 1980 provides the employers to maintain records for inspection and verification by the Institution or its official authorised for the purpose: –


i.)    Particulars of all persons employed, etc.

ii.)   Pay rolls i.e. attendance & payment records.

iii.)  Duplicate copies of the return submitted to the institution i.e. schedule  of contributions paid.

iv.)  Any other record required under the Act, Rules or Regulations.

5- Section 12 of the Act titled as officials of the Institution to check employer’s books, provides the official of the Institution to check employers books/records which is analyzed as under: –


i.)   The official(s) has/have to check the records at the establishment of the employer.

ii.)  The checking official(s) should be duly authorised by a certificate prescribed by Regulation i.e. Form PI-01 to the said Regulations.

iii.) The purpose of checking is to inquiring into the correctness of any of the particulars stated on records or returns referred to in Section 10 or ascertaining compliance any provisions of the Act.

iv.) While doing the above checking the checking official ask for as given under Section 12(1)(a) to (c) viz

          (a)    Require the employer to furnish to him such information as he may consider necessary,


          (b)    Enter the establishment/premises to examine accounts books and other documents

                  relating to employment and payment of wages.

         (c)    Examine employer, his agent or any person found in such establishment on reasonable

                  excuse believed to be an insured person.


6-    From the above it is crystal clear that all the things given in Para 5 above are connected while checking of the employers records at his establishment by the authorised official of the Institution but Section 12(1)(a) of the Act has been taken out of the context and in isolation by the said attached letter in attempt to hoodwink checking of records once in a year and instead of checking record at the establishment, their demand of submitting the documents mentioned therein in the office of the Institution is in gross violation of the law, a new method devised to harass the employers and, therefore, we bring the same to your notice to kindly take the necessary steps to stop the same.


Thanking your,


                                                                             Yours faithfully,



                                                                             For M/s. S.M. Yaqoob


Encl: As above


Copies forwarded to the following recipients: –

1.      The Federal Minister of Labour

2.      The Federal Secretary,
Ministry of Labour

3.      The President,
Employers Federation of Pakistan